Yetter Coleman secured a favorable summary judgment ruling for firm clients L.C. Eldridge Sales Co. Ltd. and Leseman Davis LLC in a patent infringement case before Judge Michael Schneider of the U.S. District Court for the Eastern District of Texas, Tyler Division. The case, L.C. Eldridge v. Azen Mfg. Pte. Ltd. et al, is a multi-defendant suit concerning engine exhaust systems used on offshore oil rigs; the defendants are suppliers of such exhaust systems, and makers and owners of oil rigs using such systems. Judge Schneider denied the defendants’ motion for summary judgment that Eldridge’s patent was invalid for indefiniteness.
The defendants raised several arguments for why the patent was fatally indefinite. For example, they asserted that it could not be determined whether some claims of the patent were method claims or system claims, due to the presence of verbs such as “configured” and “combines” in claims that otherwise were clearly system claims. However, Judge Schneider agreed with the firm’s explanation that the verbs in question simply explained the structure of the claimed system, rather than claiming the method steps for using the claimed system. The defendants also argued that the use of the phrase “adequately manipulate . . . engine exhaust gas” in certain claims rendered those claims fatally indefinite, because “adequately” was too subjective, and susceptible to different interpretations by those of ordinary skill in the art. The firm, however, pointed out several sections of the patent that provided a standard for those of skill in the art to determine the degree of manipulation of exhaust gas that would be adequate, and Judge Schneider agreed.
The Court’s comprehensive ruling (2013 WL 2285749) paves the way for the case to move forward to trial in November. Paul Yetter, Eric Chenoweth, Tom Morrow, and Chris Johnson comprise Yetter Coleman’s trial team.